ANTI-BRIBERY & ANTI-CORRUPTION POLICY  

(For Project Site Operations)  

 

1. Purpose  

The purpose of this policy is to  establish  a zero-tolerance approach toward bribery, corruption, unethical payments, and improper business advantages at project sites.  

The Company is committed to conducting business with integrity, transparency, and compliance with applicable laws.  

 

2. Scope  

This policy applies to:  

  • All employees at project sites  

  • Contract workers and temporary staff  

  • Vendors, subcontractors, and consultants  

  • Agents and representatives acting on behalf of the Company  

  • Anyone interacting with government officials, clients, or third parties  

This policy covers all project site locations.  

 

3. Policy Statement  

The Company  strictly prohibits :  

  • Offering, giving, promising, or authorizing bribes  

  • Accepting bribes or kickbacks  

  • Facilitating payments (speed money)  

  • Improper gifts, hospitality, or benefits intended to influence decisions  

  • Any activity that creates an unfair business advantage  

The Company  maintains zero tolerance  for bribery in any form.  

 

 

4. Definitions  

Bribery  – Offering, giving, receiving, or  soliciting  anything of value to improperly influence a decision.  

Corruption  – Abuse of entrusted power for private gain.  

Facilitation Payment  – Small unofficial payments made to  expedite  routine actions.  

Government Official  – Any officer or employee of a government department, public agency, or regulatory body.  

 

5. Prohibited Conduct  

At project sites, the following are  strictly prohibited :  

  1. Offering money, gifts, favors, or benefits to secure work approvals.  

  1. Providing cash or gifts to inspectors, government officials, or client representatives to influence inspection results.  

  1. Accepting kickbacks from vendors or subcontractors.  

  1. Inflating invoices to create funds for unauthorized payments.  

  1. Approving payments without proper documentation .  

  1. Making unofficial payments to obtain permits or licenses.  

  1. Misrepresenting expenses in accounts or records.  

 

6. Gifts & Hospitality Guidelines  

  • Modest and reasonable hospitality may be allowed if it is lawful and transparent.  

  • Gifts must not influence or appear to influence decision-making.  

  • Cash or cash equivalents are  strictly prohibited .  

  • Any gift above approved value must be reported to management.  

  • All gifts must be recorded in a Gift Register (if applicable).  

 

7. Vendor & Subcontractor Compliance  

  • All vendors must  comply with  this policy.  

  • Contracts shall include anti-bribery clauses.  

  • Due diligence must be conducted before vendor engagement.  

  • Payments shall only be made against valid invoices and approved  work completion .  

  • No cash payments without documented approval.  

 

8. Responsibilities  

Project Manager / Site In-Charge:  

  • Ensure compliance with this policy at  site .  

  • Communicate policy to employees and contractors.  

  • Monitor financial and procurement transactions.  

Employees:  

  • Refuse any bribe or unethical request.  

  • Immediately report suspicious activities.  

  • Maintain transparent documentation.  

Accounts Personnel:  

  • Ensure  accurate  and complete financial records.  

  • Reject undocumented or suspicious payments.  

 

9. Reporting Mechanism  

Any suspected bribery or corruption must be reported  immediately  to:  

  • Reporting Manager  

  • Head Office Compliance Officer  

  • HR Department  

  • Company Whistleblower Channel (if available)  

Reports may be made confidentially. Retaliation against whistleblowers is  strictly prohibited .  

 

10. Record Keeping  

  • All transactions must be accurately recorded.  

  • False accounting entries are prohibited.  

  • Supporting documents must be  maintained  for audit review.  

  • Periodic internal audits shall be conducted.  

 

11. Investigation Procedure  

  • All reported concerns will be investigated promptly.  

  • Confidentiality will be  maintained .  

  • Appropriate corrective and disciplinary actions will be taken.  

 

12. Disciplinary Action  

Violation of this policy may result in:  

  • Written warning  

  • Suspension  

  • Termination of employment  

  • Blacklisting of vendors  

  • Legal action under applicable laws  

 

13. Training & Awareness  

  • Anti-bribery awareness shall be included in site induction.  

  • Periodic toolbox talks or refresher training shall be conducted.  

  • Policy copy shall be displayed at project site office.  

 

14. Policy Review  

This policy shall be reviewed periodically to ensure compliance with applicable laws and best practices.